MADDEN, Judge.
The plaintiff was required to pay a Federal gift tax upon a bank account in a New York bank, which account was given him by his father. He claims that the gift was not subject to the tax, and sues for the refund of the tax.
The plaintiff's father Niels C. Jansen, was a citizen and resident of Denmark. He had for many years prior to World War II maintained a bank account in his
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